Mahendra Pratap Singh & Ors. v. State of Uttar Pradesh & Ors.
Background
The appellants were candidates in a 2011 selection process for the post of Ranker Sub-Inspector in Uttar Pradesh. They claimed they were physically unfit on the day of the physical efficiency test but were nonetheless compelled to take it, even though a government circular allowed candidates who were ill to take the test on a later date. The Allahabad High Court had already ruled on the broader issue, holding that candidates who had informed the authorities about their ailment on or before the test date could get the benefit of a re-test, but that this relief would not extend to candidates (in certain categories) who had not given such prior notice of illness.
Decision Breakdown
The Supreme Court examined the High Court's judgment and found no fault with its approach, under which protection was already available to any candidate who had informed the authorities about their ailment at or before the test. The Court clarified that if any of the present appellants had, in fact, given such notice before or at the time of the test, they were already covered by the High Court's ruling, and were permitted to approach the competent authority with supporting proof, which would then act on their case within one month in line with the High Court's judgment. Since the High Court ruling already protected genuine cases, the Court held no further orders were needed and disposed of the appeals (along with pending applications) with no order as to costs.
Lesson Learnt
When a selection exam disadvantages candidates who fall ill, courts will look for evidence of timely, contemporaneous notice of the illness to the authorities: a candidate's claim of unfitness made only after the fact, without having flagged it at or before the test, is unlikely to get special relief.